Posted By Keith the brick
Hi All
I would appreciate fellow colleagues views on employing licensed asbestos removal contractors to drill holes in to walls, ceilings or floors that may or may not have hidden asbestos.
Our organisation is involved with the refurbishment and fitout of clients premises this work often involves alterations to electrical and mechanical services.
Before working in premises we inspect the building asbestos register and if asbestos has been identified we employ an approved asbestos removal company to either work on the asbestos (penetrations) or remove the asbestos.
My query is and I use the following senario as an axample:
Works are required to replace lighting to a ceiling. The asbestos register for the building identifies a type 2 survey has been carried out and does not identify the ceiling as containing asbestos or being suspected of containing asbestos but asbestos has been noted in other areas. Remaining on the side of caution as we don't want to expose people to asbestos it can still be assumed that asbestos may be present behind the ceiling. Is an acceptable way forward to allow electricians to carry out the work using disposable overalls and FFP3 respirator mask as a precautionary measure on the proviso that should they come accross asbestos or a material that they can not identify the work stops, the supervisor has the substance analysed and if it is asbestos we then employ a licensed asbestos removal company to do the work, or should we from the out set employ a licensed asbestos removal contractor to drill the holes just in case there is hidden asbestos.
Any views or other angles on this subject would be apprecited.

Posted By MarkJAWatkins
You should really have a Type 3 survey carried out before works commence. Type 3 surveys are comissioned before renovation or demolition. You do not have to have the whole building surveyed to a Type 3 standard but you can have the areas that are subject to work surveyed to this level.


This opens up another can of worms; do you give the HSE 14 days notification that the contractor "may or may not" find any asbestos? - the HSE will tell you to have a Type 3 conducted before you start I would imagine.


There could be anything behind the area in which they are drilling. If the asbestos contractor can't see what is behind the non-asbestos wall/ceiling, how can they prevent contamination of the wall/ceiling voids from any ACM's that are present. (Task guidance sheet A1 of the Asbestos Essentials Task Manual details how to drill into AIB panels) I would say best to have Type 3 surveyed first to see what your dealing with (MAY WORK OUT CHEAPER AS WELL)


Regards,
Mark

Posted By Dave Wilson
If the project falls under CDM a Type 3 survey is required! (Reg 5 CAWR ACOP para 23).

All non-domestic property 'Duty Holders' are required to find asbestos in their premises, identify the type (or assume it is the worst type) , determine its location and condition and then manage it.(Produce an Asbestos Management plan) which MUST be broughjt to the attention of any person who may come into contact with any ACM's found or suspected.

If the building has beeen surveyed (type 2) and areas have not been sampled the report will (SHOULD) either assume it contains Asi or assume it does not.

You can work on 'licensed' ACM's however the following criteria applies, the 'strip' must not be over 1 hour or more than 2 man hours, however you will still need to be trained, use enclosures and safe stripping techniques to prevent the spread of asbestos dust, if over these limits then a licensed contractor MUST be used. (Asbestos Licensing Regs 83). This to change to 'sporadic work of low intensity' and the CD explains what this is.

Just because your staff are working on unlicensed products the full safety measures must be adopted when working on them, Type 5 overalls, FFP3 Masks using safe removal techniques, use of wetting agents and type H Vacuums. This may even be an airline fed suit in future as the Contol limts are coming down to 0.1 f/ml but depends on the expected fibre release at the point of strip.

In the proposed Asbestos Regulations 2006 (Due Oct 06) there is going to be a mandatory statutory requirement for ALL yes ALL persons in construction and the allied building trades to undergo 'Asbestos Awareness Training', that is ANYONE whose work invovles disturbing the fabric of a building, IT, CCTV, security alarm installers, Council workers, Sparkies, plumbers, FM, Maintenance teams etc etc we are talking millions of people here. If your staff do not know what is / is not an ACM they are putting themselves at serious risk for the future as they could be potentially exposed to high asbestos fibre contaminatoion on a daily basis and they would be unprotected (no mask!).

Posted By Linda Crossland-Clarke
Hiya

The licenced company will have the right insurance as well. I would think any non qualified surveyor or trades person wouldn't be able to get the insurance, so any work done on ACM wouldnt' be covered.

Regards

Linda

Posted By Dave Wilson
Its all contained in the cos Doc and draft ACOP, can email you a .pdf copy if you like as the cons period has closed so you cant get one now!

Posted By Dave Wilson
Moderators please!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

Posted By Dave Wilson
Type 3 surveys are required for major refurbishment or demolition and these would fall under CDM, a Priority Risk Assessment is not required as it is assumed tha+t any ACM's found would be removed as a part of the project.

Reg 4 (9) & (10) CAWR ACOP & Guidance

'Building / maintenance contractors will not take on any direct duties in respect of the duty to manage in reg 4, unless they have contractural responsibilities for maintenance activities or they exercise some element of control over the site. An example of the latter is where contractors exercise some or full control over part of premises for an extended period, for example where a construction or refurbishment project is 'ring-fenced' from other activities. In such cases, CDM places a CLEAR OBLIGATION on the construction client to provide information on asbestos to the contractor ................."

Now if you are doing this how can you ensure that the building contractor knows where ALL ACM's are if a type 3 is not done?

I am well aware that it is more expensive however I can, from experience! ensure you that it is cheaper in the long run as the amount of jobs which we do where a contractor has found, lagging, limpet and AIB which were not discovered on type 2 surveys and this has lead the project to over run as it will take at least 1 month to get a Licensewd contractor to deal with, argue and point finger at someone, then out to tender, evaluate tender agree price send in ASB5 and start work. Of course you can say put in the ASB 5 and we will sort the price out later etc etc but thats still two weeks before a start date.

Also the amount of 'extras' - only quoted for what was in the type 2 but a lot more has been found so there is an extra cost there.

So your project is now 2 -3 months behind, over budget and the Client is screaming at the Planning Supervisor who is incurring penalty clauses who is shouting at the Principle Contractor who is pressurising our peolpe to get the job done as quickly as possible. Any one out there recognise this? I seee this every month of the year.

Also you could be in breach of both regulation 10 and 15 not to expose your employees and not to expose others not in your employment.

Posted By Anil
Getting a competent surveying organisation (e.g. one with UKAS accreditation to IS0 17020 and working to MDHS 100) to carry out a Type 3 to the specific areas of concern would give you the assurance to proceed or plan remedial action as necessary. This would help you to manage the potential risks from possible concealed asbestos, maintain health and safety for staff/occupants, avoid potential exposure to asbestos of your electricians as well as avoiding appointing an asbestos removal contractor unnecessarily.